General Comprehensive Privacy Notice

Responsible for the protection of your personal data Equipos y Productos Químicos del Noroeste, S.A. de C.V. (CLARVI), with address located at Alfonso Cano No. 516 Oriente, Fraccionamiento El Parque, Los Mochis, Sinaloa, C.P. 81259, is responsible for the treatment of your personal data in terms of the established by article 3º fraction XIV of the Federal Law for the Protection of Personal Data in Possession of Private Parties (LFPDPPP).

Purposes of processing and type of personal data collected

In accordance with the provisions of articles 16 and 17 of the LFPDPPP, we inform you that the general, financial and patrimonial personal data collected personally, directly or indirectly by Equipos y Productos Químicos del Noroeste, S.A. de C.V. will be processed for the following essential purposes:

• Identification of customers, prospective customers, suppliers, instructors, lessors, candidates, interns, employees, contractors and visitors;
• To enter into the corresponding contract, maintain and keep custody of the respective file and information, in order to fully comply with the obligations agreed between the parties;
• Registration in databases, systems or company directories;
• Contact our prospective customers to establish a business relationship;
• Sending information and quotations requested by our clients;
• Billing;
• Recruitment, selection and/or administration of personnel (if applicable);
• Recruitment, selection and release of internships (if applicable);
• Provide employment references of our employees or former employees, or performance references of our trainees;
• Hiring, registration and payment of suppliers and instructors;
• Carrying out the signing of leases and payment to lessors;
• Receive and give attention to your complaints and suggestions, follow up on your case and offer solutions to the complaint or problem raised, generate internal reports and statistics that allow us to adapt or improve our services.
• Generate dissociated statistics about our products and/or services, and the degree of satisfaction of our customers;
• Legal proceedings, substantiation and follow-up of lawsuits;
• Allow you to participate and register in our activities and events;
• Allow you access to our facilities and maintain security within our facilities, protect our equipment and confidential information, through vehicle searches, searches of machinery, equipment or personal items, check-ins and check-outs, video surveillance cameras and intercoms;
• To facilitate your use of our website www.clarvi.com and to make your online experience on our site easier, generate separate statistics on the use of our website www.clarvi.com and official social networks;
• Updating your personal information.

The processing of personal data of customers, candidates for vacancies, employees, interns and contractors is described in the Privacy Notices corresponding to each of these holders.

2.1 Use of images

a) Surveillance: the images collected by the surveillance cameras are managed in a Closed Circuit Television, are stored on the hard disk of our server which is periodically overwritten, and will be used exclusively to ensure the security of our employees, as well as that of our equipment, facilities, systems and confidential information.

b) Intercoms: the images transmitted by the intercom camera will be used exclusively to identify our visitors and to guarantee the security of the personnel working in these facilities and visitors, as well as our equipment,
systems, confidential information and personal property. In the event that photographs are taken, they will be stored in a device that is periodically overwritten and will be used for the same purposes.

c) Events: In order to document and communicate information about the activities, courses and events organized by the company, Equipos y Productos Químicos del Noroeste, S.A. de C.V., may use, print, reproduce and publish the image(s) (photographs and/or videos) of those
persons attending or participating in our events, as well as the image of our employees or trainees, family and friends attending such events or activities, in print, electronic media (including websites, social networks and blogs), newsletters, photographic memories and publications, in all their manifestations, their interpretations or executions, their editions, their broadcasts, their phonograms or videograms for the aforementioned purpose. These images shall not be commercially exploited by

d) Social networks: CLARVI will not disclose, use, or commercially exploit the images or photographs published by users voluntarily and spontaneously within the pages of our social networks or through their personal accounts in the same.

e) Advertising: In the event that CLARVI requires to use the image (in photograph or video) of those who participate in our activities or events for advertising purposes, we will request their express consent beforehand; in the case of minors, the authorization of their parents or guardians will be requested in terms of article 425 of the Federal Civil Code.

2.2 Financial and equity data

a) Personal financial data. In the event that payment to suppliers, instructors and lessors is made via bank transfer, we will ask you to provide us with your bank account number and Standardized Banking Code (CLABE), in order to be able to make the corresponding payment
for your services.

b) Personal property data. In the event that employees, trainees, visitors, contractors, suppliers or customers enter our facilities with personal property not belonging to our company, we will ask them to make a record of the machinery, equipment or personal items in question in order to provide assistance in case of loss and maintain security within our facilities.

2.3 Secondary purposes

The general personal data of our prospective customers will be used to send information about our products or services, promotions and/or newsletters, and commercial prospecting.

Ways to limit the use of your personal data

If you do not wish to receive information about our products or services, promotions and/or newsletters, as well as market or satisfaction surveys, please send an e-mail to our Privacy Office at pacosta@clarvi.com, requesting to unsubscribe from our mailing list . Once your registration has been unsubscribed, we will send you a confirmation e-mail.

Consent to the processing of sensitive personal, financial and property data

In compliance with the provisions of articles 8 and 9 of the LFPDPPP, we inform you that in order to collect and treat your sensitive, financial and patrimonial data it is necessary to have your express consent, so at the moment we obtain such information we will indicate precisely the purpose of its collection and treatment within the respective Privacy Notice, requesting that you indicate whether or not you accept the treatment of such data. Equipos y Productos Químicos del Noroeste, S.A. de C.V. does not collect personal data catalogued as sensitive from prospective customers, customers, suppliers, instructors, lessors and visitors.

In which cases do we transmit your personal information?

Equipos y Productos Químicos del Noroeste, S.A. de C.V., may transfer the personal data of candidates, employees or interns to third parties, the purposes of such transfers are detailed within our Privacy Notices for Candidates, Employees and Interns, within each of these notices your consent will be requested. The personal contact data of our suppliers, instructors and/or contractors may be shared with CLARVI, S.A. de C.V. and CLARVI Transportes, S.A. de C.V. for the hiring of their services or the acquisition of their products, these companies are grouped under the Clarvi® brand and operate under the same privacy policies, therefore it will not be necessary to have your express consent to carry out this communication of personal data, in accordance with section III of article 37 of the LFPDPPP.

Rights of access, rectification, cancellation, opposition and revocation of consent.

You may request Equipos y Productos Químicos del Noroeste, S.A. de C.V., access, rectification, cancellation (in case it is legally appropriate) or oppose the use of personal data that have been provided, as well as revoke your consent, for which you must follow the following procedure:

• Send an e-mail to the address pacosta@clarvi.com, stating your full name, the legal or business relationship you have or have had with CLARVI (whether you are an employee, customer, visitor, etc.) and the type of right you wish to exercise.
• Fill out the ARCO request form, identifying precisely the data regarding which you are requesting access, rectification, cancellation or opposition, or those regarding which you wish to revoke your consent, attaching any of the identification documents indicated in the form in order to prove your identity or the personality with which you are making the request. Once this form is completed, it must be sent to the e-mail address indicated in the previous paragraph and any documents that are relevant to the request in question may be attached.
• For rectification requests, it is necessary for the holder to indicate precisely what the modification to be made is, attaching the documentation that justifies the origin of the request.
• Once your request is received, an Acknowledgement of Receipt will be sent to you with the corresponding folio (file) number and date of receipt. In the event that the request does not comply with the legal requirements, within five working days of receipt, you will be required to correct your request within ten days, otherwise the request will be deemed not to have been filed.
• In case your request has been sent on a non-business day, it will be received as of the next business day after you have sent it.
• Your request will be answered via email within twenty working days from the date of acknowledgement of receipt. This period may be extended for twenty additional days when there are reasons that justify it, this situation will be notified to the holder in accordance with the provisions of Article 97 of the Regulations of the LFPDPPP.
• In the event that your request is appropriate in accordance with the LFPDPPP and other current regulations, access will be granted, your data will be rectified or cancelled, your right of opposition will be enforced or your consent will be deemed revoked, within fifteen days following the date on which your request is answered. This period may be extended for an additional fifteen days when there are reasons that justify it, this situation will be notified to the holder in accordance with the provisions of Article 97 of the RLFPDPPP.
• In all the cases in which your request is appropriate, in terms of the provisions of articles 32, 33, 34 and 35 of the LFPDPPP, the delivery of the personal data will be free of charge through the e-mail address that the owner of the data indicates for such purposes, in case you require the information to be delivered in a different way, you must only cover the justified shipping costs and/or the cost of reproduction in copies or other formats that are generated.

Contact privacy office

If you have any questions about the content, interpretation or scope of our privacy notice, policies, handling of your personal information and how to express your privacy preferences, you can contact our Privacy Officer, Ing. Perla Karely Acosta Baez via e-mail at pacosta@clarvi.com.

Online Privacy Policy

The information related to the use of the portal www.clarvi.com is described below. When you enter to the portal of Equipos y Productos Químicos del Noroeste, S.A. de C.V., we We record your Internet address (this address is usually temporary and is assigned by your Internet service provider at the time you log on), the type of operating system you use and the type of browser software you use. In addition, we may track which parts of the site you are visiting. The information we collect is used to help us create a better experience for users of our website; all of this is done without us knowing your name or any other information that would allow us to identify you. While you visit the CLARVI website, you do so anonymously, unless you expressly choose to identify yourself to us.

Equipos y Productos Químicos del Noroeste, S.A. de C.V. does not require that you provide us with personal information to use the Internet portal, unless this is necessary and this necessity is explained to you in an express way. For example, some applications may require you to disclose some personal information in order for those applications to function as designed. For this purpose, our Internet portal may require you to enter information that identifies you (general data) through contact forms in order to respond to your inquiries, complaints, comments or job applications.

CLARVI may use the general information provided by its customers to offer you other products and services related to our company’s activities, but in no case will CLARVI disclose personal information to other companies that intend to sell products or services to you.

Cookies: A cookie is a brief piece of information that the website sends to your computer, which is stored on your hard drive. The next time you log on to our website, we may use the information stored in the cookie to make it easier for you to use our website. For example, we may use your cookie to store a password so that you do not have to re-enter it each time you move to a different section of our website. A cookie does not let us know your personal identity unless you expressly choose to provide it to us. Most cookies expire after a certain period of time, or can be deleted by you at any time you wish. You can also have your browser notify you when you receive a cookie so that you can accept or decline them.

To whom can you submit your complaints and denunciations about the improper processing of your personal data?

If you believe that your right to protection of personal data has been violated by any conduct or omission of our employees, or by our actions or responses, you may file a complaint or denunciation before the National Institute of Transparency, Access to Information and Protection of Personal Data, for more information visit www.inai.org.mx.

Changes to the Privacy Notice.

This Privacy Notice will be effective as of the last update date and may be modified by the responsible in terms of the applicable regulations, any changes will be communicated through our website: www.clarvi.com.

Last update: January 2, 2017